Comment Log Display

January 24, 2007




California Air Resources Board
1101 I Street
Sacramento, CA 95814

Re:  Dry Cleaning ATCM

Dear Board Members:

Sierra Club California thanks the Air Resources Board for ordering
a phaseout of Perchloroethylene (PCE) from dry cleaning. Studies of
currently available alternative systems indicate that alternative
solvents in commercial use today successfully clean as full a
range of garments as PCE. Non-PCE alternatives are just as
cost-effective or more cost-effective than PCE systems. Moreover,
there is no question that the alternative solvent systems are
commercially feasible and in broad use within the United States
and in other countries. Therefore, California should make the
transition away from PCE as soon as possible and assure that
replacement systems are safe. We believe the phaseout period for
PCE machines should be reduced to 10 years to protect workers and
the public.

Alternative solvent systems such as wet-cleaning evolved from
emerging technologies to commercially viable systems that have
taken their place as established technologies in the industry.
Numerous studies and reports regarding alternative solvent systems
demonstrate that such systems are comparable to PCE systems in
quality of cleaning, range of garments cleaned, and cost. As a
result, it is now achievable for dry cleaners to eliminate PCE
emissions through process changes and substitution of materials.
Specifically, when dry cleaners’ PCE machines wear out, they can
replace those machines with machines that use non-PCE
alternatives. Moreover, they can do so cost-effectively and at no
greater cost than using PCE machines. 

A quicker phaseout of PCE is justified by research findings that
point to a 10-year life expectancy for PCE machines. In 2000,
William Fisher, Chief Executive Officer at International Fabricare
Institute, testified to the US House of Representatives
Subcommittee that the anticipated life of a PCE machine is “eight
to 12 to 14 years” depending on the model.

During its 2001 rulemaking on the phase-out of PCE, the South
Coast Air Quality Management District initially proposed a phase
out of Perc dry cleaning systems that allowed machines a lifetime
of nine to 10 years. In 2005, the Eastern Research Group (ERG),
which provided background information for USEPA’s development of
the current National Emissions Standards for Hazardous Air
Pollutants (NESHAP), quantified the "Economic Life" for a dry
cleaning machine as 10 years.  In a Memorandum dated May 16, 2005
to US EPA’s Rhea Jones, ERG’s Eric Goehl and Mike Heaney note that
the "life of a dry cleaning machine was determined during the
development of the current NESHAP.” 

Additionally, we believe that a full implementation of AB 998
(Lowenthal, 2003) will decrease the actual cost of the transition
to safer substitutes. AB 998, which we supported, directed ARB to
apply a fee on the PCE used in dry cleaning to establish a
demonstration program for non-toxic, non-smog forming
alternatives, and use the additional funds for grants to cleaners
making the transition from PCE to these safer alternatives.  

Our understanding is that more than three years after this law
took effect ARB:  1) is still not fully collecting fees on all the
PCE used by California dry cleaners, 2) has not initiated a single
demonstration program, and 3) has only made 23 grants in a state
with almost 5,000 dry cleaners.  ARB can do more to support
cleaners’ transition by fully implementing AB 998.  

Despite the extraordinary toxicity of PCE, many Americans are
unaware of the health risks created by exposure to PCE emissions.
This risk is especially high for people who live in the same
building as a PCE dry cleaner. The risks are also especially high
for people who spend any time in the same building as a PCE dry
cleaner — e.g. children who go to a day care center in the same
building as a PCE dry cleaner — and for the neighbors of a PCE dry
cleaner. Therefore, we support the draft proposal’s requirement for
removal of all PCE machines from co-residential locations, and we
ask the Board to expedite the removal of PCE machines that are
located in close proximity to homes, schools, day care centers and
other sensitive sites.

Sincerely,


Bill Magavern
Senior Representative